Agriculture Production

USDA's Preparation for Asian Soybean Rust Gao ID: GAO-05-668R May 17, 2005

In November 2004, Asian Soybean Rust (ASR) was discovered in the United States in Louisiana. In the following weeks, it was found in eight additional southern states. ASR is a harmful fungal disease that has spread throughout many other parts of the world, including Asia, Australia, Africa, and South America. ASR can infect over 90 host plant species, including legumes, such as dry beans, peas, and kudzu, a plant that grows wild primarily in the southern United States. Although the disease has caused significant soybean crop loss and increased production costs in many other countries, ASR arrived in the United States too late in the crop year to have any effect on soybean production in 2004, and scientists were uncertain about how it would survive the winter climates in the United States. However, in February 2005, researchers found that ASR had successfully over-wintered on kudzu in Florida, and it was subsequently detected in Georgia on soybean plants in April 2005. Since environmental factors, such as rainfall, humidity, and temperature, affect both the severity and incidence of ASR, scientists do not know how widespread or damaging the disease will be in the United States during the 2005 crop year. The U.S. Department of Agriculture (USDA) is responsible for monitoring and addressing the problems posed by ASR. The Environmental Protection Agency (EPA) is responsible for licensing fungicides to treat the disease. Congress asked us to determine (1) USDA's efforts to develop and implement an ASR surveillance strategy to identify and protect against ASR's entry into the United States and to test and verify suspect cases; (2) USDA's strategy for minimizing the effects of ASR now that the fungus has arrived in the United States; and (3) the progress that USDA, EPA, and others have made in developing, testing, and licensing fungicides to treat ASR and in identifying and breeding ASR-resistant or -tolerant soybeans.

In May 2002, after ASR was identified in Brazil, USDA began planning for the introduction of ASR into the continental United States. Three USDA agencies--the Animal and Plant Health Inspection Service (APHIS), the Cooperative State Research, Education, and Extension Service (CSREES), and the Agricultural Research Service (ARS)--the National Plant Board, industry, and several land-grant universities formed an ad hoc Soybean Rust Committee. At about the same time, USDA established the National Plant Diagnostic Network to enable diagnosticians, state regulatory personnel, and first detectors to communicate information, images, and methods of detection for ASR and other diseases in a timely manner. In the fall of 2002, USDA began disseminating information and conducting training courses in an effort to educate growers about how to identify and manage the disease. In January 2004, APHIS issued a strategic plan that provided information on the protection, detection, response, and recovery from ASR. While generally comprehensive in its coverage of issues, the plan was not fully developed when ASR was first identified in the United States. Since the initial discovery of ASR in the continental United States, USDA and others have increased efforts to inform growers about how to identify and minimize the effects of the disease. In April 2005, USDA issued A Coordinated Framework for Soybean Rust Surveillance, Reporting, Prediction, Management and Outreach. The framework includes a surveillance and monitoring network, a Web-based information management system, decision criteria for fungicide application, predictive modeling, and outreach efforts. We surveyed 31 soybean-producing states to obtain information about their efforts, in coordination with USDA, to prepare for and manage ASR. The states generally responded positively when discussing efforts to educate growers and others on ASR and in setting up sentinel plot monitoring programs. (Sentinel plots will be planted earlier than commercial plants to alert growers if ASR is present in their region.) However, some of the states reported that their diagnostic laboratories may have insufficient funding and/or staff to test suspected samples for ASR. In addition, most states indicated that they were either uncertain or did not believe they would have enough equipment available to apply fungicides to treat the disease. The American Soybean Association, representing many of the nation's largest soybean growers, has also expressed concerns about whether growers will have access to equipment as well as fungicides in a timely manner. Finally, USDA's Risk Management Agency has recently developed additional guidance on the actions growers must take to ensure that any losses due to ASR are covered under their insurance policies. However, growers have expressed concerns about what they need to do to demonstrate good farming practices in treating ASR and the documentation they must provide to demonstrate that they followed such practices. Further guidance may be needed because of the uncertainties associated in dealing with the disease. USDA, EPA, and others have made significant progress in developing, testing, and licensing fungicides to treat ASR. As of April 2005, eight fungicides were registered with EPA for treating ASR. In addition, EPA had approved emergency exemptions for an additional 11 fungicides to treat ASR under section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act. As of April 2005, 32 states had applied for and been granted section 18 exemptions that are effective through November 10, 2007. USDA estimates that researchers are 5 to 9 years away from identifying or breeding ASR-resistant or -tolerant soybeans. In addition, on March 10, 2005, USDA removed ASR from the list of select agents and toxins, which removed certain restrictions and will aid ongoing research on the disease in the United States.



GAO-05-668R, Agriculture Production: USDA's Preparation for Asian Soybean Rust This is the accessible text file for GAO report number GAO-05-668R entitled 'Agriculture Production: USDA's Preparation for Asian Soybean Rust' which was released on May 23, 2005. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. United States Government Accountability Office: Washington, DC 20548: May 17, 2005: The Honorable Tom Harkin: Ranking Democratic Member: Committee on Agriculture, Nutrition, and Forestry: United States Senate: Subject: Agriculture Production: USDA's Preparation for Asian Soybean Rust: Dear Senator Harkin: In November 2004, Asian Soybean Rust (ASR) was discovered in the United States in Louisiana. In the following weeks, it was found in eight additional southern states. ASR is a harmful fungal disease that has spread throughout many other parts of the world, including Asia, Australia, Africa, and South America. ASR can infect over 90 host plant species, including legumes, such as dry beans, peas, and kudzu, a plant that grows wild primarily in the southern United States. Although the disease has caused significant soybean crop loss and increased production costs in many other countries, ASR arrived in the United States too late in the crop year to have any effect on soybean production in 2004, and scientists were uncertain about how it would survive the winter climates in the United States. However, in February 2005, researchers found that ASR had successfully over-wintered on kudzu in Florida, and it was subsequently detected in Georgia on soybean plants in April 2005. Since environmental factors, such as rainfall, humidity, and temperature, affect both the severity and incidence of ASR, scientists do not know how widespread or damaging the disease will be in the United States during the 2005 crop year. The U.S. Department of Agriculture (USDA) is responsible for monitoring and addressing the problems posed by ASR. The Environmental Protection Agency (EPA) is responsible for licensing fungicides to treat the disease. You asked us to determine (1) USDA's efforts to develop and implement an ASR surveillance strategy to identify and protect against ASR's entry into the United States and to test and verify suspect cases; (2) USDA's strategy for minimizing the effects of ASR now that the fungus has arrived in the United States; and (3) the progress that USDA, EPA, and others have made in developing, testing, and licensing fungicides to treat ASR and in identifying and breeding ASR-resistant or -tolerant soybeans. We provided your staff with a formal briefing on our findings on April 28, 2005. In that briefing, we cited USDA's lack of funding for ASR oversight as an area of concern. On May 12, 2005, the Secretary of Agriculture announced that USDA will use about $1.2 million in contingency funding to help monitor, report, and manage soybean rust during the 2005 growing season. This report summarizes the results of our April 28TH briefing, and enclosure I presents our briefing slides. To respond to your questions, we met with USDA and EPA officials and visited state, industry, and soybean association officials and university extension faculty in Georgia, Indiana, Iowa, Louisiana, and Minnesota. We selected these states to provide geographic representation of states where soybeans are grown. We also conducted a survey of 31 soybean-producing states in April 2005. Enclosure II describes our scope and methodology, and enclosure III presents our survey results. We performed our work from December 2004 through April 2005 in accordance with generally accepted government auditing standards. In summary, we found the following: In May 2002, after ASR was identified in Brazil, USDA began planning for the introduction of ASR into the continental United States. Three USDA agencies--the Animal and Plant Health Inspection Service (APHIS), the Cooperative State Research, Education, and Extension Service (CSREES), and the Agricultural Research Service (ARS)--the National Plant Board, industry, and several land-grant universities formed an ad hoc Soybean Rust Committee. At about the same time, USDA established the National Plant Diagnostic Network to enable diagnosticians, state regulatory personnel, and first detectors to communicate information, images, and methods of detection for ASR and other diseases in a timely manner. In the fall of 2002, USDA began disseminating information and conducting training courses in an effort to educate growers about how to identify and manage the disease. In January 2004, APHIS issued a strategic plan that provided information on the protection, detection, response, and recovery from ASR. While generally comprehensive in its coverage of issues, the plan was not fully developed when ASR was first identified in the United States. Since the initial discovery of ASR in the continental United States, USDA and others have increased efforts to inform growers about how to identify and minimize the effects of the disease. In April 2005, USDA issued A Coordinated Framework for Soybean Rust Surveillance, Reporting, Prediction, Management and Outreach. The framework includes a surveillance and monitoring network, a Web-based information management system, decision criteria for fungicide application, predictive modeling, and outreach efforts. We surveyed 31 soybean- producing states to obtain information about their efforts, in coordination with USDA, to prepare for and manage ASR. The states generally responded positively when discussing efforts to educate growers and others on ASR and in setting up sentinel plot monitoring programs. (Sentinel plots will be planted earlier than commercial plants to alert growers if ASR is present in their region.) However, some of the states reported that their diagnostic laboratories may have insufficient funding and/or staff to test suspected samples for ASR. In addition, most states indicated that they were either uncertain or did not believe they would have enough equipment available to apply fungicides to treat the disease. The American Soybean Association, representing many of the nation's largest soybean growers, has also expressed concerns about whether growers will have access to equipment as well as fungicides in a timely manner. Finally, USDA's Risk Management Agency has recently developed additional guidance on the actions growers must take to ensure that any losses due to ASR are covered under their insurance policies. However, growers have expressed concerns about what they need to do to demonstrate good farming practices in treating ASR and the documentation they must provide to demonstrate that they followed such practices. Further guidance may be needed because of the uncertainties associated in dealing with the disease. USDA, EPA, and others have made significant progress in developing, testing, and licensing fungicides to treat ASR. As of April 2005, eight fungicides were registered with EPA for treating ASR. In addition, EPA had approved emergency exemptions for an additional 11 fungicides to treat ASR under section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act. Section 18 exemptions provide designated states with an emergency exemption to temporarily use a fungicide. As of April 2005, 32 states had applied for and been granted section 18 exemptions that are effective through November 10, 2007. USDA estimates that researchers are 5 to 9 years away from identifying or breeding ASR- resistant or -tolerant soybeans. In addition, on March 10, 2005, USDA removed ASR from the list of select agents and toxins, which removed certain restrictions and will aid ongoing research on the disease in the United States. We met with USDA's Special Assistant for Pest Management Policy and APHIS, ARS, CSREES, the Economic Research Service (ERS), and RMA officials to discuss the facts in this report. We also discussed the report with officials in EPA's Office of Pesticide Programs. USDA and EPA generally agreed with the information in our report and provided some clarifying comments that we incorporated as appropriate. As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution of it until 30 days from the date of this letter. We will then send copies of this report to the Secretary of Agriculture and the Administrator of EPA. In addition, this report will be available at no charge on the GAO Web site at http://www.gao.gov. If you have any questions about this report or need additional information, please contact me at (202) 512-3841. Key contributors to this report were James L. Dishmon, Jr., Chad M. Gorman, Ronald E. Maxon, Jr., Lynn M. Musser, and Deborah S. Ortega. Sincerely yours, Signed by: Robert A. Robinson: Managing Director, Natural Resources and Environment: Enclosures - 3: Enclosure I: USDA's Preparation for Asian Soybean Rust: Briefing for Senator Tom Harkin: Ranking Democratic Member: Committee on Agriculture, Nutrition, and Forestry: United States Senate: April 28, 2005: Background: In November 2004, Asian Soybean Rust (ASR) --Phakopsora pachyrhizi--was first discovered in the continental U.S. in Louisiana. ASR is a harmful fungal disease that has caused economic losses in Asia, Australia, Africa, and South America because it decreases crop yield and increases fungicide costs. Environmental factors, such as rainfall, humidity, and temperature, affect both the severity and incidence of ASR. Long periods of leaf wetness, high humidity, and temperatures between 60 and 85 degrees Fahrenheit are ideal for spore germination. ASR can infect over 90 host plant species of legumes, such as dry beans and peas, and kudzu, which grows wild in the southern U.S. There are no commercial U.S. soybean cultivars with resistance or tolerance to ASR. Fungicides are currently the primary tools for managing ASR. However, growers must be knowledgeable about the various types of preventative and curative fungicides as well as when and how to apply them. An April 2004 USDA study projected U.S. losses between $640m and $1.3b in the first year of ASR's arrival. Objectives: Provide Information on: * USDA's surveillance strategy to identify and protect against ASR entry into the U.S. * USDA's strategy and actions to minimize the effects of ASR now that it is in the U.S. * USDA, EPA, and others' progress in developing, testing, and licensing fungicides to treat ASR and in developing rust-resistant or rust- tolerant soybeans. Scope and Methodology: Met with USDA and EPA officials and visited state, industry, and soybean association officials and university extension faculty in Georgia, Indiana, Iowa, Louisiana, and Minnesota. Surveyed 31 soybean-producing states: * Training and Education: * Sentinel Plots: * First Detectors: * Laboratory Facilities and Staff: * Fungicides and Application Equipment: Objective 1: USDA's Preparation for ASR: In May 2002, after ASR was identified in Brazil, three USDA agencies-- the Animal and Plant Health Inspection Service (APHIS), the Cooperative State Research, Education, and Extension Service (CSREES), and the Agricultural Research Service (ARS)--joined with the National Plant Board, industry, and several land grant universities to form an ad hoc Soybean Rust Committee. In June 2002, USDA established the National Plant Diagnostic Network (NPDN) to allow diagnosticians, state regulatory personnel, and first detectors to communicate information, images, and methods of disease detection in a timely manner. In November 2002, USDA began conducting training to educate growers and others about how to identify and manage ASR. In January 2004, APHIS issued a strategic plan providing information on how to detect, respond to, and recover from ASR. The strategic plan appeared to be comprehensive in its coverage of issues, but ASR was identified in Louisiana before many aspects of the plan were fully developed. In September 2004, USDA participated in a mock field exercise held in Minnesota to prepare for ASR. In October 2004, USDA issued standard operating procedures for plant diagnostic laboratories to deal with ASR. The procedures included information about the symptoms of the disease; protocols for screening, examining, shipping, storing, and destroying ASR samples; and guidelines for who should be notified of the results. USDA supported states' efforts to obtain EPA emergency fungicide approvals. Objective 2: USDA's Efforts to Minimize the Effects of ASR: In January 2005, USDA issued a draft copy of A Coordinated Framework for Soybean Rust Surveillance, Reporting, Prediction, and Management. The final framework was issued in April 2005. The framework includes: 1. A surveillance and monitoring network, 2. A Web-based information system, 3. Decision criteria for fungicide application, 4. Predictive modeling, 5. Outreach for training, education, and disseminating information. Training & Education: Before the November 2004 discovery of ASR, land-grant universities had given over 300 presentations, programs, and workshops to educate growers about ASR detection and fungicides. Since the discovery of ASR, they have given about 1,500 additional presentations, programs, and workshops. In 30 of the 31 states we surveyed, training covered identification of ASR and "look-alike" diseases and available fungicides; 25 states covered ASR tracking and forecasting information; and 25 states covered application methods. Sentinel Plots: The sentinel plot program has three functions: 1. Serve as an early warning system. 2. Quantify the timing of spore production. 3. Provide means to collect data for research. Sentinel plot data, along with data collected by mobile field monitoring teams and industry, will be entered into USDA's Soybean Rust Monitoring and Prediction System. USDA has established a Web site that will use sentinel plot data to allow viewers to monitor the progress of the disease on a daily basis. States reported that they plan to have 347 USDA plots, 516 university- sponsored plots, and 186 other plots. Most states reported various factors for determining the number and distribution of sentinel plots. The most common factors were location of plot within the state and distribution of soybeans within the state. Only 15 states reported that scientific data, such as wind patterns, crop yield, or rainfall, were factors. In most states, a combination of people will monitor the plots. The number of monitors that the states plan to train varied, ranging from 1 to 300. USDA has recommended that the states plant 320 plots at a projected cost of $800,000, but USDA has not yet provided funding. The North Central Soybean Research Program (NCSRP) and the United Soybean Board (USB) have provided $389,000 for a sentinel plot program consisting of 20 plots to be established in each of 20 states. The total amount of funding that the states anticipate receiving also varied. The states anticipate receiving over $500,000 from USDA and approximately $390,000 from the North Central Soybean Research Program and the United Soybean Board. First Detectors: The states reported that they have already trained over 5,000 first detectors to assist growers in their efforts to detect ASR and that they plan to train over 1,000 more this year. First detectors include: extension personnel, crop consultants, agribusiness employees or consultants, state department of agriculture personnel, growers, USDA/APHIS personnel, and master gardeners. 30 states indicated that first detectors were being given instructions on how to prepare, and where to send, samples for confirmation of ASR. Laboratory Facilities and Staff: State labs have allocated $0 to $91,000 for testing samples for ASR in 2005. The amount of funding that the labs believe is needed to run the 2005 ASR testing program varied, ranging from $0 to $150,000. USDA estimates that each state will require $45,000 for diagnostic staff and equipment dedicated to diagnosing ASR. States' Assessment of Laboratory Facilities and Staff for ASR Testing: ASR testing: Sufficient staff? Probably or definitely yes: 18; Probably or definitely no: 7; Uncertain: 6. ASR testing: Sufficient funding? Probably or definitely yes: 10; Probably or definitely no: 7; Uncertain: 14. Source: GAO's analysis of state survey data. [End of table] Fungicides and Application Equipment: Surveyed states reported that their growers and commercial applicators probably or definitely had a good understanding of: * available fungicides (27 states), * when to apply fungicides (23 states), * the appropriate methods for applying fungicides for ASR (23 states). Estimated Percent of Soybean Growers Who Own Equipment to Apply Fungicide: Estimated percent: 1-25%; Number of states: 6. Estimated percent: 26-50%; Number of states: 7. Estimated percent: 51-75%; Number of states: 3. Estimated percent: 76-99%; Number of states: 4. Estimated percent: 100%; Number of states: 2. Estimated percent: Uncertain; Number of states: 9. Source: GAO's analysis of state survey data. [End of table] Fungicides and Application Equipment: 8 states believe there are enough commercial applicators to provide service to growers in their states who do not own equipment to apply ASR fungicide. 5 states do not believe there is sufficient equipment, and the remaining 17 states indicated that they were uncertain. 1 state did not respond. Estimates for the percentage of soybean acreage that could be sprayed within 5 days following the confirmation of ASR in the states we surveyed ranged from a low of 20 to a high of 100 percent. Chemical companies that manufacture fungicides approved by EPA for use on ASR declined to go on record with the quantities they had on hand or planned to manufacture. A trade association representing crop protection chemical companies has stated that it believes the industry will be responsive to growers in managing the disease during the 2005 crop year. The American Soybean Association has expressed concerns regarding the availability of fungicides. ASR Disease Forecast/Predictive Models: The Soybean Rust Aerobiology Prediction System is a collaborative project between Pennsylvania State and North Carolina State Universities and ZedX, Inc. Iowa State University is developing forecast models using predicted daily weather data from an atmospheric model to make short-term predictions of ASR risk in different geographic areas. The North American Disease Forecast Center at North Carolina State University will also provide ASR disease forecasts. Crop Insurance Coverage: USDA's Risk Management Agency (RMA) has stated that losses of insured growers will be covered if they follow "good farming practices.": 12 of the 31 soybean-producing states indicated the information provided by RMA is sufficient for use in extension presentations to growers on ASR; 18 were uncertain, while 1 said it is not. RMA stated that it has recently provided insurers with guidance regarding what steps growers must take to insure that their losses will be covered. Objective 3: Licensing Fungicides and Developing Rust-Resistant Soybeans: As of April 25, 2005, 8 fungicide products (4 active ingredients) were registered with EPA for treating ASR in the U.S. In addition, EPA has approved 11 fungicide products for treating ASR under section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Section 18 quarantine exemptions grant three years of temporary use rights in specified states. 32 states have received section 18 emergency exemptions for 6 or more fungicide products. Most of the states we surveyed reported that they did not have difficulties obtaining EPA section 18 emergency exemption approvals for ASR fungicides. 26 states have obtained information or consulted with officials from Brazil or other countries regarding lessons learned about applying fungicides to treat ASR. 27 states believe that growers and commercial applicators in their states have a good understanding of the types and product names of fungicides to treat ASR. USDA estimates that its researchers will identify soybean germplasm with some level of rust resistance within 5 years and that industry will require an additional 2-4 years to develop commercial soybean lines with resistance. On March 10, 2005, USDA removed ASR from the list of select agents and toxins, which will allow for additional research to be conducted in the U.S. In April 2005, USDA issued its National Strategic Plan for the Coordination and Integration of Soybean Rust Research. Areas of Concern: USDA has not provided funding to the states for the sentinel plots. However, if the states do not monitor the plots as recommended, the quality of the data used in the forecasting systems and for future research could be jeopardized. Fungicides and application equipment may be insufficient to meet the needs of growers if and when ASR occurs. The predictive models have not yet been validated, and there are questions about the timely reporting of data. RMA may need to issue additional guidance regarding what steps growers must take to insure that their losses will be covered. Although USDA's framework is generally comprehensive, more information is needed regarding how it will be implemented. [End of slide presentation] Enclosure II: Scope and Methodology: To determine the U.S. Department of Agriculture's (USDA) efforts to develop and implement an Asian Soybean Rust (ASR) surveillance strategy to identify and protect against ASR's entry into the United States and to test and verify suspect cases, we interviewed officials from USDA's Animal and Plant Health Inspection Service (APHIS), Cooperative State Research, Education, and Extension Service (CSREES), and Agricultural Research Service (ARS) to identify actions that the department took before November 2004, when the first case of ASR was confirmed in the continental United States. In addition, we discussed these actions with USDA's Special Assistant for Pest Management Policy. We also reviewed pertinent documents regarding USDA's efforts to educate growers and others to identify, report, and test suspected cases of ASR. To determine USDA's strategy for minimizing the effects of ASR now that the fungus has arrived in the United States, we interviewed officials from USDA's APHIS, CSREES, ARS, Farm Service Agency (FSA), and Risk Management Agency (RMA) to identify efforts that have been implemented since November 2004. We also surveyed the 31 soybean-producing states that were included in USDA's sentinel plot program to obtain information on their efforts to minimize the effects of ASR through education, training, surveillance, and testing. We pretested the content and format of the survey questionnaire with officials in four states. During these pretests, we asked the officials to assess whether the questions were clear and unbiased and whether the terms were accurate and precise. We made changes to the questionnaire based on pretest results. We also conducted site visits to Georgia, Indiana, Iowa, Louisiana, and Minnesota, where we met with officials from land- grant universities, field-based extension offices, state departments of agriculture, and state soybean associations and check-off boards to gain more in-depth information about their efforts to mitigate the effects of ASR.[Footnote 1] We also interviewed industry and trade representatives to discuss the adequacy of available fungicides and application equipment. To determine the progress that USDA, the Environmental Protection Agency (EPA), and others have made in developing, testing, and licensing fungicides to treat ASR and in identifying and breeding ASR- resistant or -tolerant soybeans, we interviewed officials from USDA, EPA, and state departments of agriculture to obtain information about their efforts to license fungicides to treat ASR. We also interviewed ARS personnel as well as researchers from academia and industry and reviewed related reports and studies regarding efforts to identify and breed ASR-resistant or -tolerant soybeans. We performed our work from December 2004 through April 2005 in accordance with generally accepted government auditing standards. [End of section] Enclosure III: Survey of Soybean-Producing States: Preparations for Asian Soybean Rust: [See PDF for image] Note: The total for question 6 does not equal the subtotals in 6a and 6b because some sentinel plots will use both soybeans and non-soybean hosts. Note: The total for question 11 does not equal the subtotals in 11a and 11b because some sentinel plots will use both soybeans and non-soybean hosts. [End of figure] [End of section] (360578): FOOTNOTES [1] A check-off board is an industry-funded marketing and research program that promotes an agricultural product.

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